The US’s and the EU’s Generalised System of Preferences: A Comparison in the Context of Workers’ Rights

In the context of recent GSP changes, especially the Trump Administration’s steps relating to certain beneficiary countries, it is timely to assess the effectiveness of this unilateral mechanism. In particular, the academic question connected to the impact of the GSP on social development and human rights in the beneficiary countries is the key issue. It is also interesting to what extent the threat of blocking imports or the withdrawal from the scheme can give rise to policy change regarding labour standards. This article aims to analyse the legal basis, and compare the EU’s and the US’s GSP labour provisions. The author applies critical reasoning and comparative analysis with a view to showing the differences between both countries. She focuses her attention on advantages and disadvantages of the GSP schemes – not only those currently in effect in the US and the EU, but also from a historical perspective.